Conflict of Interest Management Policy

Conflict of Interest Management Policy

Revised April 1, 2025

Interactive Brokers Securities, Inc.

1. Purpose

Interactive Brokers Securities, Inc. (hereinafter referred to as “the Company”) shall, pursuant to Article 70-4 of the Cabinet Office Ordinance on Financial Instruments Business, etc., identify and categorize transactions that may unfairly impair the interests of customers (hereinafter referred to as “Covered Transactions”), and established the following management system for Covered Transactions to prevent customers' interests from being unfairly impaired by Covered Transactions, and hereby publicly announces the system.

2. Identification and categorization of Covered Transactions

We will identify and categorize Covered Transactions as follows.

Transaction Type Customer - Company or Group Company Customer - Other Customer
Conflict of interest Conflict of Interest Transaction in which the customer has a conflict of interest with the Company or its group company Transaction in which the customer has a conflict of interest with another customer of the Company or its group company
Competitive Competitive Transaction in which the customer and the Company or its group company compete for the same object Transaction in which the Company or its group company competes with another customer of the Company or its group company
Information Use Transaction in which our company or our group company obtains profit by using information obtained by our company or our group company through a relationship with a customer Information Use Type Transaction in which the Company or its group company benefits from information obtained by the Company or its group company through the relationship with the customer

Examples:

Conflict of Interest:

  • Where our company or our group company may obtain economic profit or avoid economic loss at the expense of the customer.
  • Where in connection with a transaction with a person other than the customer, inducement is, and will be, obtained in the form of money, goods or services other than usual fees and expenses. The Company or a member of the Company's group is involved in the same transaction in more than one capacity and cannot expect the transaction to have the same terms and conditions as a normal transaction.
  • The Company or a member of the Company's group conducts a transaction with a customer who should be protected by the Company or the Company's group.
  • The Company or its group company enters into a transaction with a counterparty of a customer who should be protected by the Company or its group company.

Competitive Transaction:

  • The Company or its group company enters into a competitive transaction with a counterparty of a customer who should be protected by the Company or its group company.

Information Use Type:

  • The Company or its group company enters into a transaction for its own benefit through use, etc. of non-public information on a customer who should be protected by the Company or its group company.

Others:

  • When an employee of a securities firm, etc. receives a gift or entertainment (including non-monetary gifts) that may have an effect that conflicts with the interests of a customer.

3. Method of Managing Covered Transactions

In principle, the Company shall manage Covered Transactions by any of the following methods or a combination thereof.

  1. Separating the division that conducts the Covered Transaction from the division that conducts the transaction with the relevant customer.
  2. Changing the terms or method of the Covered Transaction or the transaction with the relevant customer.
  3. Discontinuing the Covered Transaction or the transaction with the relevant customer.
  4. Disclosing appropriately to the relevant customer that the interests of the relevant customer may be unjustly impaired in relation to the Covered Transaction.
  5. Monitoring of information-sharing parties of the Covered Transaction.

4. Management System for Covered Transactions

The Company shall appoint the Chief Internal Control Officer as the Chief Conflict of Interest Management Officer, who shall be independent from other divisions such as sales division and shall endeavor to ensure an appropriate conflict of interest management system.

The Company shall centrally manage all Target Transactions that may occur within the Company. Conflicts of interest that may arise between customers of the Company and the Group Companies listed below, or between customers of the Company and customers of the Group Companies listed below, shall be managed by the Interactive Brokers Group, the parent company of the Company.

5. Scope of Companies Subject to Conflict-of-Interest Management

The group companies subject to conflict-of-interest management at IBSJ are as follows:

Interactive Brokers Group, Inc.

  1. Interactive Brokers LLC
  2. Interactive Brokers Canada Inc.
  3. Interactive Brokers Australia Pty. Ltd
  4. Interactive Brokers (U.K.) Limited
  5. Interactive Brokers India Pvt. Ltd.
  6. Interactive Brokers Hong Kong Limited
  7. Interactive Brokers Ireland Limited
  8. Interactive Brokers Singapore Pte. Ltd.